G/SPS/GEN/2180  
 
21 November  2023 
(23-7847) Page: 1/1 
Committee on Sanitary and Phytosanitary Measures  Original: English  
 
  
EUROPEAN UNION  REVIEW OF LEGISLATION ON VETERINARY MEDIC INAL PRODUCTS  
– SPECIFIC TRADE CONCERN 446  
SUBMISSION BY THE UNITED STATES  OF AMERICA  
The following submission, received on 20 November  2023, is the statement made by the 
United  States of America at the 15-17 November 2023 WTO SPS Committee, and is being  circulated 
at the request of the Delegation of the United States  of America . 
 
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1.  This is the thirteenth time the United States has raised its concerns in this Committee on the 
implementation of Article 118 of EU regulation 2019/6.  
2.  The United States continues to stress that the EU regulation will unnecessarily limit access to 
animal production practices that are necessary an d appropriate for farmers and producers within 
their own countries and that pose no food safety risks.  
3.  The United States requests that the European Union consider alternative regulatory approaches 
by third country systems that achieve the EU level of prote ction. Members require flexibility in how 
they use veterinary medicines. Unilateral restriction by the European Union on the use of specific 
production practices in other countries unnecessarily hinders the ability of producers in those 
countries to raise animals in the most efficient and sustainable manner for their local conditions.  
4.  The United States again requests scientific evidence that demonstrates that this EU measure will 
significantly and effectively reduce the occurrence of foodborne antimicrobial  resistance.  
5.  The World Health Organization and Codex Alimentarius differentiate between medically important 
and non -medically important antimicrobials. This is an important differentiation as non -medically 
important antimicrobials have been deemed safe for use as growth promoters. Growth promoters 
safely and efficiently increase yield; through their use, feed and other inputs may be optimized for 
animals to reach market weight more quickly, which can result in production systems that are more 
environment ally and economically sustainable than other approaches.  
6.  The United States understands that the European Union is contemplating a 30 -month transition 
period, which would be impractical for the implementation of these measures, as it does not take 
into cons ideration the lifespan of different animal species or the shelf and storage life of products 
already in the supply chain.  
7.  The United States also seeks clarification as to the date upon which the transition period begins, 
as it appears as though the 30 -month transition period from the E uropean Union's 28 February 2022 
application date has already started, which would mean that agricultural producers in the European 
Union and in third countries must already be transitioning their production practices based on  a 
measure that has not been fully defined or implemented within the European Union.  
8.  As we continue to move forward, we expect the European Union to meaningfully engage with 
Members through bilateral consultations to mitigate any potential trade disruption s, and the 
United  States remains available to further discuss implementation of Article 118.  
 
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